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A common cross-border reorganization can doom eligibility for the valuable gain exclusion without thoughtful planning.
Current developments in S corporations This annual update covers recent developments relating to S corporations, including IRS relief for common inadvertent S election lapses; the transfer of ...
Profits–interest partners frequently are allocated a share of the gain recognized in connection with a liquidity event. This allocation can lead to unexpected results related to Sec. 1245 recapture.
A Joint Committee on Taxation report’s language raises questions about the running of the statute of limitation for liability for the Sec. 965 transition tax.
The Eighth Circuit, affirming a district court, held that because a wife had no property interest in a home owned by her husband that was sold in a judicial sale to satisfy his federal tax debts, she ...
Intangible property transactions are a minority of those covered by advance pricing agreements, despite their generally high risk for taxpayers.
Although the deadline for filing a challenge to an IRS employment status determination is nonjurisdictional, an employer’s facts did not warrant equitable tolling, the Tax Court held.
If tax-exempt entities invest in energy projects through partnerships, careful consideration should be given to allocations under the respective partnership arrangements to avoid any detrimental ...
John Sapp, CPA, vice president, brand ambassador, Drake Software, discusses how artificial intelligence (AI) can be a powerful tool in the tax and accounting profession.
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